Privacy and Cookie Notice

This Notice explains how Prime Frontier International Minerals Corp. (“Provider”, “we” or “us”) collects, uses, shares and protects personal information in connection with the mydrillingoperations.com website, MDO accounts and applications (including offline-enabled applications), support, sales and related services.

1. 1.Who We Are

   1. Provider is a company incorporated under the laws of British Columbia, trading as Prime Frontier Minerals, with its registered office at 666 Burrard Street, Park Place, Vancouver, British Columbia V6C 3P6, Canada. Provider operates MyDrillingOperations (“MDO”).
   2. Our privacy contact can be reached at privacy@mydrillingoperations.com.

2. 2.Our Role

   1. For website visitors, prospective customers, account administration, billing and our direct communications, we decide why and how personal information is used and are responsible for it as a controller.
   2. For workforce, project, HSE, geological and operational information that a customer enters into MDO, the customer decides the purposes of processing. We process that information on the customer's instructions as its processor or service provider, under our agreement with that customer.
   3. If you use MDO through your employer or another organisation, that organisation's own privacy notice also applies, and requests about that information should normally be directed to it first.

3. 3.Information We Collect

   1. Depending on how you interact with us, we may collect:
      • Identity and contact details, such as name, employer, role, email address and telephone number;
      • Account information, such as user identifiers, credentials, permissions and authentication and access logs;
      • Device and usage information, such as browser and device type, approximate location derived from IP address, and application events;
      • Communications, such as support requests, correspondence and meeting notes;
      • Billing information, such as billing contact details and payment records (card details are handled by our payment processor, not stored by us); and
      • Information entered by customers into MDO, which may include project assignments, shifts, qualifications, certifications, training, local-content classifications, HSE incident information and operational records attributable to users.

4. 4.Sources

   1. We obtain information directly from you; from the organisation that provides your account; through your use of the website and MDO; from integrations configured by a customer; and from service providers that support hosting, authentication and payments.

5. 5.How We Use Information

   1. We use personal information to:
      • Create, administer and secure accounts;
      • Provide, synchronize, support and maintain MDO;
      • Maintain audit records;
      • Process payments and manage billing;
      • Send service, security and contractual notices;
      • Prevent fraud and misuse;
      • Diagnose issues and improve performance;
      • Manage customer relationships and, where permitted, send marketing communications; and
      • Comply with legal obligations.

6. 6.Legal Grounds

   1. Where the law requires a legal basis, we rely on performance of a contract, our legitimate interests in operating and improving MDO, compliance with legal obligations, protection of vital interests or, where required, consent.
   2. Customers are responsible for establishing an appropriate legal basis and giving any required notices for personal information they enter into MDO.

7. 7.Sensitive Information

   1. HSE and workforce records may contain health or other sensitive information. Customers should collect only what is necessary, configure permissions carefully and avoid unnecessary sensitive details in free-text fields.

8. 8.Sharing

   1. We share personal information only with authorised users of the relevant customer account; with service providers that help us operate MDO, such as cloud hosting, payment processing and email providers, under written data protection terms (customers may request our current subprocessor register at privacy@mydrillingoperations.com); with professional advisers under confidentiality; in connection with a merger, acquisition or other corporate transaction; and where required by law.
   2. We do not sell personal information.

9. 9.International Transfers

   1. Provider is based in Canada. MDO and its service providers, including those located in the United States, may process information outside your country.
   2. Where the law applicable to an individual or customer restricts cross-border transfers, including the UK GDPR, the ECOWAS Supplementary Act A/SA.1/01/10 on Personal Data Protection and national laws such as Côte d'Ivoire Law No. 2013-450, Senegal Law No. 2008-12, Ghana's Data Protection Act, 2012 (Act 843) and the Nigeria Data Protection Act 2023, we rely on a transfer mechanism recognised by that law. This may include contractual safeguards and, where required, a declaration to or authorisation from the competent data protection authority.
   3. Customers must identify any project, regulatory or licence-specific data localisation requirements before deployment.

10. 10.Retention

    1. We keep personal information for the duration of the customer's subscription and the agreed export period, and then delete or anonymise it in accordance with our retention schedule, subject to backup cycles and legal obligations.
    2. Security, billing, contractual and legal records may be kept longer where necessary for those purposes.

11. 11.Security

    1. We use reasonable safeguards designed to protect confidentiality, integrity and availability, including access controls, encryption in transit, encryption at rest where supported, logging, backups and incident response. Users must protect their credentials and devices.

12. 12.Your Rights

    1. Depending on where you are, you may have rights to access, correct, delete, restrict or object to the processing of your personal information, to data portability, to withdraw consent and to complain to a regulator.
    2. To exercise your rights, contact privacy@mydrillingoperations.com. Requests about information controlled by a customer will normally be referred to that customer.

13. 13.Cookies

    1. Our website and application use strictly necessary cookies and similar technologies for security, sessions and preferences.
    2. Analytics or marketing technologies are used only where permitted by law and, where required, after you consent. You can change your choices at any time through Cookie Settings.
    3. The categories, providers and durations of cookies in use are set out in the Schedule.

14. 14.Automated Decisions

    1. MDO calculates indicators, flags and workflow recommendations from data supplied by customers. Unless we specifically disclose otherwise, we do not make solely automated decisions that produce legal or similarly significant effects about individuals.

15. 15.Children

    1. MDO is a business service and is not directed to children.

16. 16.Regulators and Complaints

    1. You may contact our privacy contact about our practices at any time.
    2. Depending on your location, you may also complain to the Office of the Privacy Commissioner of Canada or a provincial commissioner, the UK Information Commissioner's Office, the Autorité de Régulation des Télécommunications/TIC de Côte d'Ivoire (ARTCI), the Commission de Protection des Données Personnelles (CDP) in Senegal, the Data Protection Commission in Ghana, the Nigeria Data Protection Commission or another competent authority.

17. 17.Changes to This Notice

    1. We may update this Notice to reflect changes to our services, the law or our operations. We will communicate material changes where required.

18. 18.Contact

    1. Privacy enquiries: privacy@mydrillingoperations.com. Postal address: Prime Frontier International Minerals Corp., 666 Burrard Street, Park Place, Vancouver, British Columbia V6C 3P6, Canada.

Last update: October 1, 2026